Text extracted via OCR from the original document. May contain errors from the scanning process.
ATTORNEY OR PARTY %WHOLLY ATTORNEY (Name, Slate 8 a r nwnbw, And address):
JONATHAN B. COLE (70460)
VINCENT S. GREEN(231046)
NEMECEK & COLE
15260 Ventura Blvd., Suite 920
Sherman Oaks, CA 91403
TELEPHONE NO •
.
TAX NO. (000480.
E-MAIL ADORESS (Option's°.
ATTORNEY FOR (Name): Plaintiff
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Los Angeles
STREET ADDRESS: 111 North Hill
Street
CRY AND ZIP COOE: Los Angeles, California
90012
BRANCH NAM£ CENTRAL DISTRICT
PLAINTIFF/PETITIONER: SITRICK AND COMPANY, a division of
DEFENDANT/RESPONDENT: JEFFREY EPSTEIN; an individual;
DOES 1 through 20, inclusive
and
NOTICE AND ACKNOWLEDGMENT OF RECEIPT—CIVIL
CASE NUMBER:
BC502448
TO (insert name of party being served): JEFFREY EPSTEIN
NOTICE
The summons and other documents identified below are being served pursuant to section 415.30 of the California Code of Civil
Procedure. Your failure to complete this form and return it within 20 days from the date of mailing shown below may subject you
(or the party on whose behalf you are being served) to liability for the payment of any expenses incurred in serving a summons
on you in any other manner permitted by law.
If you are being served on behalf of a corporation, an unincorporated association (including a partnership), or other entity, this
form must be signed by you in the name of such entity or by a person authorized to receive service of process on behalf of such
entity. In all other cases, this form must be signed by you personally or by a person authorized by you to acknowledge receipt of
summons. If you return this form to the sender, service of a summons is deemed complete on the day you sign the
acknowledgment of receipt below.
Date of mailing: MARCH 12 , 2013
(TYPE OR PRINT NAME)
(SIGNATURE OF SENDER-MJST NOT BE A PARTY IN THIS CASE)
This acknowledges receipt of (to be completed by sender before mailing):
1.
A copy of the summons and of the complaint.
2
Other (specify): NOTICE OF CASE ASSIGNMENT - UNLIMITED CIVIL CASE
(To be completed by recipient):
Date this form is signed:
(TYPE OR PRINT YOUR NAME AND NAME OF ENTITY, IF ANY,
(SIGNATURE OF PERSON ACKNOWLEDGING RECEIPT. WITH TITLE IF
ON WHOSE BEHALF THIS FORA! IS SIGNED)
Pape toll
Form &NOW ferMardifty Use
Asdidel Court-II ol Callfcenia
POS-015 [Rev. Mowry I, 2005)
sot
NOTICE AND ACKNOWLEDGMENT OF RECEIPT — CIVIL
Ca
d CiYil Pnlajda
It) 415.30, 417.10
u ns-
Cat
EFTA01121352
POS-015
ATTOMETORWMCYMTHOUTAT1MRNEY(aentaWBecownemaWm0w):
JONATHAN B. COLE (70460)
VINCENT S. GREEN(231046)
NEMECEK & COLE
15260 Ventura Blvd., Suite 920
Sherman Oaks, CA 91403
TELEPHONE NO.:
Emsamomsfloptimo:
KnowcynmNmo Plaintiff
TAX NO. (Optionao.
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Los Angeles
STREET/400RM 111 North Hill Street
CITY AND ZIP CODE: Los Angeles, California 90012
PLAINTIFF)PEITTIONER: SITRICK AND COMPANY, a division of
DEFENDANT/FtESPONDENT: JEFFREY EPSTEIN; an individual; and
DOES 1 through 20, inclusive
FORCOORTMWOMY
NOTICE AND ACKNOWLEDGMENT OF RECEIPT—CIVIL
CASE WINER.
BC502448
TO (insert name of party being served): JEFFREY EPSTEIN
NOTICE
The summons and other documents identified below are being served pursuant to section 415.30 of the California Code of Civil
Procedure. Your failure to complete this form and return it within 20 days from the date of mailing shown below may subject you
(or the party on whose behalf you are being served) to liability for the payment of any expenses incurred in serving a summons
on you in any other manner permitted by law.
If you are being served on behalf of a corporation, an unincorporated association (including a partnership), or other entity, this
form must be signed by you in the name of such entity or by a person authorized to receive service of prooess on behalf of such
entity. In all other cases, this form must be signed by you personalty or by a person authorized by you to acknowledge receipt of
summons. If you return this form to the sender, service of a summons is deemed complete on the day you sign the
acknowledgment of receipt below.
Date of mailing: MARCH 12 , 2013
(TYPE OR PRINT NAVE)
(SIGNATURE OF SENDER-MUST NOT BE A PARTY IN THIS CASE)
This acknowledges receipt of (to be completed by sender before mailing):
1.
A copy of the summons and of the complaint.
2.
Other: (specify): NOTICE OF CASE ASSIGNMENT - UNLIMITED CIVIL CASE
(To be completed by recipient):
Date this form is signed:
(TYPE OR PRINT YOUR NAME AND NAME OF ENTITY. IF ANY.
(SIGNATURE OF PERSON AOCNOWLEDGING RECEPT. WITH TITLE IF
Pe0e1c41
Form Aeopexl Tor lee/WMory UM
Judoal C0IACII of California
POS-015(Rev. Jenury1.2006]
Cade of Cell Pm:flak
St 415.30.417.10
EFTA01121353
SUMMONS
(CITACION JUDICIAL)
NOTICE TO DEFENDANT: JEFFREY EPSTEIN; an individual
;
(AVISO AL DEMANDADO): and DOES 1 through 20, inclusive
SUM-100
(SOLO PARA USO DE LA CORTE)
EONFOOSIED COPY
OfgQINAL FILED
ethic, mon. or emArostwa
MAR 07 2013
YOU ARE BEING SUED BY PLAINTIFF: SITRICK AND COMPANY, a
(LO ESTA DEMANDANDO EL DEMANDANTE): division
of SITRICIP A.Ctarke,Excc ve 0fficer:Clerk
.
MUNCH° GROUP, LLC
By
epwy
1 va
NOTICE! You have been sued. The court may decide against you without your being heard unless you respond within 30 days. Read the information
below.
You have 30 CALENDAR DAYS after this summons and legal papers are served on you to file a written response at this court and have a copy
served on the plaintiff. A letter or phone call will not protect you. Your written response must be in proper legal form if you want the court to hear your
case. There may be a court form that you can use for your response. You can find these court forms and more information at the California Courts
Online Self-Help Center (www.courtin(o.ca.goviselfhelp). your county law library, or the courthouse nearest you. If you cannot pay the filing fee, ask
the court clerk for a fee waiver form. If you do not file your response on time, you may lose the case by default, and your wages, money, and property
may be taken without further warning from the court.
There are other legal requirements. You may want to call an attorney right away. If you do not know an attorney, you may want to call an attorney
referral service. If you cannot afford an attorney, you may be eligible for free legal services from a nonprofit legal services program. You can locate
these nonprofit groups at the Califomia Legal Services Web site (wvnv.lawhelpcalifomia.org), the California Courts Online Self-Help Center
(vnvve.courtinfo.ca.goviselfhelp), or by contacting your local court or county bar association. NOTE: The court has a statutory lien for waived fees and
costs on any settlement or arbitration award of $10,000 or more in a civil case. The courts lien must be paid before the court will dismiss the case.
jAVISOI Lo han demandado. Si no responder dentro de 30 dies, Is code puede decidir en su contra sin escucher su version. Lea la information a
continuation
Tiene 30 DIAS DE CALENDARIO despues de que le entreguen esta citation y papeles legates pare presenter una respuesta par escrito en esta
code y facer que se entregue una copia al demandante. Una carte o one Ilameds teleldnica no lo protegen. Su respuesta poi escrito hens que ester
en formato legal conecto si desea que procesen su caso en la code. Es posible que hays un fommlario qua usted puede user pare su respuesta.
Puede enoontrar estos formularios de la cote y nes infonnaci0n en el Centro de Ayuda de las Cortes de California (\wnv.sucorte.ca.gov), en la
bablioteca de /eyes de su condado o en la code que le quede mos cotta. Si no puede pager /a errata de presentation, pida al secretarto de la code
que le de un lormulario de exencien de pago de cuotas. Si no presents su respuesta a tiempo, puede perder el caso poi incumplimiento y la code le
padre quitar su avoid°, dinero y bienes sin mos advertencb.
Hay otros requisitos regales. Es recomendable que flame a un abogado inmediatamente. Si no conoce a an abogado, puede Ilamar a un servier0 de
remision a abogados. Si no puede pager a un abogado, es posible que cumpla con los requisitos pare obtener servicios regales gratuitos de un
programa de servicios legates sin fines de lucro. Puede encontrar estos grupos sin fines de lucro en el sitio web de California Legal Services,
kvivr.lawhelpcalifomis.org), en el Centro de Ayuda de las Cones de California, (wonv.sucorte.ca.gov) o pomendose en contacto con la cone o el
colegio de abogados locales. A VISO: Par ley, la cone bane derecho a reclamar las motes y los costos exentos poi imponer un gravamen sobre
cuabuier recuperation de $10,000 0 mes de valor recibida mediante un acuerdo o una concesion de arbitraje en un caw de derecho civil. Tiene que
pager el gravamen de la torte antes de que la cone puede desechar el caso.
I he name and address of the court is:
(El nombre y direcci0n de la code es):
Los Angeles Superior
Court
Central
District
BC5 24 4
111 North Hill
Street
Los Angeles, California
90012
The name, address, and telephone number of plaintiffs attorney, or plaintiff without an attorney, is:
(El nombre, la direction y el n0mero de telefono del abogado del demandante, o del demandante ue no lien
s :
JONATHAN B. COLE ( 7 04 6 0 ) VINCENT S. GREEN (231046)
NEMECEK & COLE
1 5 2 6 0 Ventura Blvd.
Sherman Oaks, CA 9 1 4 03
DATE:
•Intin A.
Clerk, by
Deputy
(Fettle)
mow
(Secretario)
(Adjunto)
(For proof of service of this summons, use Proof of Service of Summons (form POS-010).)
(Pam prueba de entrega de este citation use el formulario Proof of Service of Summons, (POS-010)).
NOTICE TO THE PERSON SERVED: You are served
1. ET as an individual defendant.
2. ni as the person sued under the fictitious name of (specify):
3. n
on behalf of (specify):
under: in CCP 416.10 (corporation)
ni
CCP 416.60 (minor)
CCP 416.20 (defunct corporation)
El
CCP 416.70 (conservatee)
CCP 416.40 (association or partnership) n CCP 416.90 (authorized person)
other (specify):
4.
1 by personal delivery on (date):
Pego1 oil
SUMMONS
(SEAL)
MAR 07 2013
Ern Adopted for Mandatory use
API081C0j01 of Coithrenta
SUM-100 (Roy. Jury 1, 200B]
CASE NUMBER:
(Piers* cki Coco)
nose or Chi Procedure IS 412.20. 455
EFTA01121354
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JONATHAN B. COLE (70460)
VINCENT S. GREEN (231046)
15260 Ventura Boulevard, Suite 920
She
91403
Tel:
Fax: MM.
Attorneys for Plaintiff SITRICK AND COMPANY,
a division of SITRICK BRINCKO GROUP, LLC
CONFOUNIth
orticiriAL ritx
soptiopmcR,ootri.cosrAtivitant
MAR 0 7 2013
Psi
John A. Clarke, Exec we Officentlerk
BY
-
vs
SITRICK AND COMPANY, a division of
Plaintiff,
VS.
JEFFREY EPSTEIN, an individual; and
DOES 1 through 20, inclusive,
Defendants.
)
)
) )
)
) )
)
)
) )
)
Case No. BC502448
BASED UPON:
(1) BREACH OF CONTRACT;
(2) BREACH OF ORAL CONTRACT;
(3) COMMON COUNTS;
(4) ACCOUNT STATED;
(5) OPEN BOOK ACCOUNT; AND
(6) QUANTUM MERUIT
Plaintiff, SITRICK and COMPANY, a division of SITRICK BRINCKO GROUP, LLC
("Plaintiff") complains and alleges as follows:
1.
Plaintiff is and at all times herein mentioned was, a limited liability company
organized and existing under and pursuant to the laws of the State of California and
doing business in the State of California, with its principal place of business located in
Los Angeles County.
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2.
Plaintiff is informed and believes, and thereon alleges, that defendant
JEFFREY EPSTEIN ("Epstein") is, and at all times relevant hereto was, a citizen of and
residing in the State of Florida.
3.
Epstein has engaged in the necessary minimal contacts with the State of
California for this Court to entertain personal jurisdiction, including, but not limited to,
entering into a contract in California with a California limited liability company, phone calls
and emails to Plaintiff in California for strategy and advice, and paying for services
delivered from California.
4.
On or about November 4, 2005, Epstein entered into a written contract
(the "Contract") with Plaintiff to provide advice and public relations services. The
Contract provides it may be terminated with 30 days written notice by either party. The
Contract has never been terminated. A true and correct copy of the contract is attached
hereto as Exhibit 1.
5.
On or about March 11, 2011, Epstein entered an oral contract with Plaintiff
(the "Oral Contract") to provide consulting advice and public relations services concerning
Epstein's relationship with Prince Andrew of England.
6.
The true names and capacities of Defendants DOES 1 through 20,
inclusive, whether individual, corporate, associate, or otherwise, are unknown to Plaintiff
at this time, who therefore sues said Defendants by such fictitious names, and when the
true names and capacities of such Defendants are ascertained, Plaintiff will seek leave of
Court to amend this Complaint to insert same. Plaintiff is informed and believes and
thereon alleges that each Defendant named as a DOE is responsible for each and every
act and obligation hereinafter set forth.
7.
Plaintiff is informed and believes and thereon alleges that each Defendant
named in this Complaint was at all times herein mentioned and now is the agent, servant
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EFTA01121356
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and employee of the other Defendants herein, and was at all such times acting within the
course and scope of said agency and employment and with the consent and permission
of each of the other co-Defendants, and each of the Defendants herein ratified each of
the acts of each of the other co-Defendants, and each of them.
8.
The obligation sued upon herein was incurred in and is payable in the
County of Los Angeles, State of California.
9.
Said obligation is commercial in nature, not based upon a retail installment
sales contract or a conditional sales contract, and not subject to the provisions of Civil
Code §§1812.10 and 2984.4.
(Breach Of Written Contract as Against Epstein and Does 1 through 20, and Each
of Them)
10.
Plaintiff repeats, realleges and incorporates herein by reference the
allegations of paragraphs 1 through 4 and 6 through 9, inclusive, as though set forth at
length.
11.
Pursuant to the terms of said Contract, entered into by and between
Plaintiff and Epstein on or about November 4, 2005, Plaintiff agreed to provide advice
and public relations services to Epstein, and Epstein agreed to pay for these services.
12.
Plaintiff has sent written statements of account to Epstein listing the
amount of its indebtedness to the Plaintiff and requesting payment therefore from
Epstein.
13.
On or about July 8, 2011, Epstein breached the Contract by failing to pay
Plaintiff for the advice and public relations services rendered.
14.
Plaintiff has performed all conditions, covenants and promises required on
its part to be performed in accordance with the terms and conditions of the Contract
except as excused by the breach of Epstein
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15.
Pursuant to the terms of said Contract, and as a result of Epstein breach of
said Contract, the Plaintiff has been damaged in the sum of $103,517.82, together with
interest thereon at the legal rate from the date the obligations were due, and said sum is
now due and owing.
(Breach of Oral Contract as Against Epstein and Does 1 through 20, and Each of
Them)
16.
Plaintiff repeats, realleges and incorporates herein by reference the
allegations of paragraphs 1 through 3 and 5 through 9, inclusive, as though set forth at
length.
17.
Pursuant to the terms of said Oral Contract, entered into by and between
Plaintiff and Epstein on or about March 11, 2011, Plaintiff agreed to provide advice and
public relations services to Epstein, and Epstein agreed to pay for these services.
18.
Plaintiff has sent written statements of account to Epstein listing the
amount of its indebtedness to the Plaintiff and requesting payment therefore from
Epstein.
19.
On or about July 8, 2011, Epstein breached the Oral Contract by failing to
pay Plaintiff for the advice and public relations services rendered.
20.
Plaintiff has performed all conditions, covenants and promises required on
its part to be performed in accordance with the terms and conditions of the Oral Contract
except as excused by the breach of Epstein.
21.
Pursuant to the terms of said Oral Contract, and as a result of Epstein
breach of said Oral Contract, the Plaintiff has been damaged in the sum of $103,517.82,
together with interest thereon at the legal rate from the date the obligations were due,
and said sum is now due and owing.
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(Open Book Account For Reasonable Value Of Services Rendered as Against
Epstein, and Does 1 through 20, and Each of Them)
22.
Plaintiff repeats, realleges and incorporates herein by reference the
allegations of paragraphs 1 through 9, inclusive, as though fully set forth at length herein.
23.
Within the last four years, at Los Angeles County, California, Epstein,
became indebted to Plaintiff in the sum of $103,517.82 as and for the balance due upon
an open book account for advice and public relations services provided by Plaintiff to
Epstein based upon the Contract and Oral Contract. Pursuant to the Contract and Oral
Contract, payment was promised and agreed by Epstein to be made. Billing records of
legal fees and costs incurred by Epstein, including debits and credits, were kept in the
regular course of business by Plaintiff and kept in a reasonably permanent form reflecting
an open book account in the aggregate reasonable value of $103,517.82.
24.
No part of said sum has been paid, although demand therefore has been
made, and there remains due, owing and unpaid from Epstein to Plaintiff the sum of
$103,517.82 together with interest thereon at the legal rate from the date the obligations
were due.
(Open Book Account, For Agreed Value Of Services as Against Epstein, and Does
1 through 20, and Each of Them)
25.
Plaintiff repeats, realleges and incorporates herein by reference the
allegations of paragraphs 1 through 9, inclusive, as though fully set forth at length herein.
26.
Within the last four years, at Los Angeles County, California, Esptein
became indebted to Plaintiff for legal services provided by Plaintiff to Epstein at its
specific instance on an open book account in the agreed value of $103,517.82.
27.
No part of said sum has been paid, although demand therefore has been
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made, and there remains due, owing and unpaid from Epstein to Plaintiff the sum of
$103,517.82, together with interest thereon at the legal rate from the date the obligations
were due.
(Account Stated Against Epstein, and Does 1 through 20, and Each of Them)
28.
Plaintiff repeats, realleges and incorporates herein by reference the
allegations of paragraphs 1 through 9, inclusive, as though fully set forth at length herein.
29.
Within the last four years, at Los Angeles County, California, an account
was stated by and between Plaintiff and Epstein, wherein and whereby it was agreed that
Epstein was indebted to Plaintiff in the sum of $103,517.82, which sum Epstein agreed
and promised to pay, and that no part of the same has been paid.
. 30.
No part of said sum has been paid, although demand therefore has been
made, and there remains due, owing and unpaid from Epstein to Plaintiff the sum of
$103,517.82, together with interest thereon at the legal rate from the date the obligations
were due.
(Quantum Meruit Against Epstein and Does 1 through 20, and Each of Them)
31.
Plaintiff repeats, realleges and incorporates herein by reference the
allegations of paragraphs 1 through 9, inclusive, as though fully set forth at length herein.
32.
Between on or about November 2005 through June 2011, Plaintiff
performed public relations services on behalf of Epstein for which Epstein promised to
pay Plaintiff at its fair and reasonable value.
33.
Demand for payment for these services has been made by Plaintiff to
Epstein, but Plaintiff has not been paid.
34.
The fair and reasonable value of said services equals not less than
$103,517.82 or an amount to be proven at trial.
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35.
Epstein has failed and refused, and continues to fail and refuse, to pay
Plaintiff for said services, leaving a balance immediately due to Plaintiff according to
proof, but in no event less than $103,517.82, together with interest thereon at the rate of
10% per annum from the date said sum became due.
WHEREFORE, Plaintiff prays judgment against Epstein, and Does 1 through 20,
and each of them, as follows:
1.
For damages in the sum of $103,517.82, together with interest thereon at
the legal rate from the date the obligations were due;
2.
For reasonable attorneys as provided for by the Contract;
2.
For costs of suit incurred herein; and,
3.
For such other relief as the Court deems just and proper.
Dated: March
2013
NEMECEK & COLE
By: (imrAi-i4-
JO
THAN B. COLE
Attorneys for Plaintiff
a division of SITRICK BRINCKO GROUP, LLC
7
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EFTA01121361
Plaintiff SITRICK and COMPANY, a division of SITRICK BRINCKO GROUP, LLC,
demands a trial by jury on all claims.
Dated: March
2013
NEMECEK & COLE
By:
--//--
Attorneys for Plaintiff
a division of SITRICK BRINCKO GROUP, LLC
8
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EFTA01121362
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EFTA01121363
Facottkr^saar titoympc.l.s.Pdt_.
• -
LCISAMZLIS tfiFT KOS
Noronha 4,2005
Roy Black, Esq.
Black, StebniekKatispan & Stumpf
201 S. Biscayne /31., /11300
Miami, FL 33131
Dear Roy.
114 later. When accepted by you below oo behalf oflef Rey Ermein (the *Client') and
accepted by Black. Stebnick, Romspan & Stumpf (*Anomie:1, will prostitute the agreement
with respect to the engagement of Sitrick And Company Inc., a California eomontion
rSlirlelti as corporate coinmunieations advraot, specialist and non-desimmtcd expert
consultant, with =poet to any legal issues Attorney is kindling for Client on the followitig terms
and conditions:
1.
The MGM and Attorney, effective as of October 21, 2005, have nixed Slott to
provide advice and public Malian soviets in COnneCtial with legal isnot it is
handling.
2.
Shriek will waive its canonry non-refundable retainer of $60,000 us a minimum,
mural fec. hi lieu thereof,• Company shall pay &wick a non-rtfialdshic retsina of
530,000 as a minimum, annual fee- Sitrick's lime charges will be billed against the
retainer at the hourly rate range of $165 to $650 depending cut the porton performing the.
ScritiOng Pgrainbre.timintiassintanl nom is billed at 355.00 per hour. Mini the retainer
bas beat applied against time charges, additional time charges in any yar still be billed
as incurred and arc payable within twenty days after receipt Muses arc computed to
portal-toponal basis for any travel time foe meetings held outside of Sinick's *from
Tine is billed by Sitrick in increments of one-quancr of an hour.
In addition, we custOnlarily inquest s 'IMAMS fee' if we believe we have Fit:donned
services for a client which result in significant benefits to the client beyond those we
believe a nomad public relations flan could achieve. Obviousty, we would sit down and
discuss any such proposed foe with you if we believe if:swan-need, as such fix would
be subject to your approval
Please review.our bilk each month upon roocipt. If you have any tiliesnOnSi please feel
toe to call However, =less you make some protest to Subtle in writing within twenty
days of receipt of the bill, it will be presumed you have no objections to it and amp: to
the reasonableness of the bill.
3.
The Client shall reimburse Siltick within twenty days of invoice time for any and all out
of pocket costs sad espouses matured by Sitrick in connection with its engeganem
I NO Carlo P
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EFTA01121364
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hereunder, including without limitation, travel eons, production costs, long distance and
photocopy charge. and other out-of-pocket costs and expenses. Reimbursable toms are
not applied against the teener and will be billed monthly by &trick.
4.
Sitrick acknowledges that its savices being provided pursuant to this letter apt-anent an
for the benefit of Client and St Attorney. as Clients comet. shall nut be responsible for
any feat, costs or expenses haeutred in coon...Mice with Sinick's services.
5.
Sitrick And Company's engagement hereunder may be terminated by either party on 30
dims prior written notice. All provisions of this later relating to the payment of fees and
expenses and indannifteadon will 4u4Yht any temithation of the engagement by either
piny. All the peovisions of this id= contained in paragraphs 4, 5. 6 sod 7 will survive
for a period of Iwo years following the date of any 441117114t100 of the engagement by
either party.
6.
In the event any employee of Shtick, a
sissy time is requited or requested to pannipate or
provide testimony, dneuannis or other evidence in any anion. arbitration or other
proceeding relating, directly or indirectly, to ow engagement. whether or not our
engagement has been terminated, the Client shall pay Sitric for the time spent in
preparing for and providing such participation or testimony. at Sinick's that standard
bilking MILS. end for any costs and expense; including anosneys feu, incurred in
connection therewith.
7.
• Client agnxs to indemnify and hold harmless Sitrick, its shareholders, officers, directors,
employees and agents (each such entity or person bring referred to as all 'Indemnified
Person') from and against any and all losses, claims, damages, liabilities, costs and
expenses (including, but not limited to, framable attomeis feat) which any Indemnified
Person may be subject to or incur in connector, with the service rendered by Sitticl. to
Chet and/or Attorney. This ptragraph shall out apply to any such losses, dams,
&tinges, liabilities. costs or expenses of any lade:omitted Person that are judiciaDy
Cearniotel to have resulted from Shriek's or such other Indemnified Person's gross
negligence or willful misconduct.
8.
Each of the parties hereto agrees to keep this letter agreement, and the tan and
conditions hereof, including billing stalemate and time sheets, aridly confidential,
except only as arty be accessary to enforce this letter.
MI communications,
correspondence, instruments and writings between Sete and Attorney shall be deemed
to cantione attorney work-product and otherwise protected by the attorney-client
privilege. Each of the parties agrees not to solicit for employment, nor aoploy, any
employee of the other during the pending of Shriek's amusement and for a period of two
yews themeler.
9.
Any ma not paid to Shriek pursuance to this agreement within ten days seen due dull
beat interest at the rate of son percent pa mown If action be commenced to enforce any
2
1510 Cria..47
•
SO367-2 Kr/
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EFTA01121365
Spott Koinspap z loySlack.pctf
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SITRICX AND COMPANY 1NC.
Lai 1.1921.1S•INEVAIR
Novemba 4. 2005
provision of this letter agreement, the prevailing pray shall be entitled to reasonable
attorney fees. Any conuoverry, chim or dispute relating to this letter agreement shell be
resolved by binding arbitration in accordance with the rules of the American Arbitration
Association pursuant to an arbitration conducted in Len Angeles County, California.
Judgment upon such tutritrntice may be catered in any court having turrsdietion thereof.
This letter agreement shall be interpreted and enforced in accordance with the substantive
las of the State of CaNecenin applicable to commas mode and to be performed therein.
Very truly )ours.
Chaim= and Chief &motive Officer
Agreed to and accepted this
le(„by or
ad vt"1
r"
'Attorney"
Coansel
Cheat
By SC-14 !Cy-
fti 4v'er
•fo. ISht k. Cie; n. r. Kr IC 04,es,
3
C.einury
Vs=
000.1.111
9000.11C9
•
EFTA01121366
Scott Korpspan - RoySiack.pdf
SiTRICK AND COMPANY INC
Alatit • MOOVOIOC
November 4.2005
Roy Black, Esq.
Stebnick, Komsmm & Stumpf
201 S. Bbxaysto 1:11., /1300
MIA* FL 33131
Re
Jeffrey Epstein
INVOICE
RetsRo' cc for the period beginning:
October 21,
Retlandabk Expeaseactance
$5,000.00
TOTAL DUE ..._...__...__..__.______.___._
S35,000.OO
Please wire troisfer funds to:
min ACCOUNT OF: *MUCK. AND COMPANY
ABA ROMTNO NO.: 122 016 066
CREDIT ACCOUNT Nat 112294570
Kam wake cluck payshk to:
MD Canary Put East, Sum 900
Lob
7
Fed. ID No. 95.4 19873$
4
EFTA01121367
Cue Number
THIS FORM IS TO BE SERVED WITH MR SUMMONS AND COMPLAINT BC 5 024t8
Your ease is auigasd for all purposes to the judicial offica indicated below (Local Hide 33(4). There Is additional hilbroatioa on the rause side mum form.
ASSIGNED JUDGE
DEPT
ROOM
ASSIGNED JUDGE
• • -
'DEPT
ROOM
Hon. Daniel Buckley
1
534
Hon. Debro Katz Weintraub
47
507
Hot Michael P.1 Infield
10
631
Hon. Elizabeth Allen White
. ... , ..
.
48
506
Hon. Sahara A. Mei=
12
636
Hon. Deirdre HE
49
509
Hon. Terry A. Gnat
14
300
Hon. John L. Segal
50
508
Hoe. Richard Bruin
. 15
307
. .
.
.
Hon Abraham !then
51
511
Hon. Rita Miller
16
306
Hon. Susan BryaubD•sason
52
510
Hon. Richard E. Rico
17
309. .
Hon. Steven J. Kthffield
53
513 .
Hon. Kevin C. Braila
C.0
---..
10
Hon. En est 14. lEroshige
54
512
Boa Robot L. Hess
24
314
Hon. Malcolm H. Mackey
55
515 .
Hon. Mary Ann Murphy
25
317
Hon./46de' Iothisim
' 56
514
Hon. James R. Dunn
26
316
Hon. Ralph W. Dais
57
517
Hon. Yvette M. Palameios
28
318
Nov Rthibi Tree . .
58
516
Hon. Barbara Scheper
30
400
Hon. David L Minning
61
632
Hon. Alan S. Rosatheld
31
407
Hon. Michael L Stan
62
600
Hca. Mary H. Strobel
32
406
Hon. MatIcMocthiy
.
. .
68
617
Hon. Charity F. Palma
33
409
Hon. Ramona See
69
621
Hon. Amy D. Hogue
. 34
408
Hon. Soussan O. Wagner&
71
729
nunaszipar
35
411
Hon.
Kwan
72
731
Hai Gregory Alarcon
'
36
410
Hoo. Tenth Sanchez-Gordon
74
. 735
Hon. Joanne O'Donnell
37
117
Hon. Willthin.F. Fahey
78
730
Hon. Manm:ca
.
Duffy-Lewis
38
412
Hon, Softie 1EL P.1.1
324
CCW
.
. .
. .
Eon, Michelle R.
•
• 414
Hon, Ehliu M. Berle
323
CCW
Hon. Remold M. Soligien
41
417
Other
Hots. Bally E. Yawns
,
42
416
Hon. Mel Red Reams
45
529
Hon. Fredrick C. Sheller
-
46
601
Given to the Plaintifl7Cross-ComplitinaTht/Atterney of Record on
JOHN A. CLARKE, Executive Ofraceric kik
By
, Deputy Cleric
LACIV poi 194 (Roy. 01112)
1.ASC Approved 0540
For Optional tiara
Page led 2
EFTA01121368
The following critical provisions of the Chapter Three Rules, as applicable in the Central District, are summarized for your assistance.
APPLICATION
The Chapter Three Rules were effective January 1, 1994. They apply to all general civil cases.
The Chapter Three Rules shall have priority over all other Local Rules to the extent the others are inconsistent
A challenge under Code of Civil Procedure section 170.6 mast be made within 15 days after notice of assignment for all purposes to
a judge, or if a party has not yet appeared, within 15 days of the first appearance.
TIME STANDARDS
Cases assigned to the Individual Calaadaring Court will be subject to processing under the following time standards:
COMPLAINTS: All complaints shall be served within 60 days of filing and proof of service shall be filed within 90 days of filing.
CROSS-COMPLAINTS: Without leave of court first being obtained, no cross-complaint may be filed by any party after their
answer is filed Cross-cothplaints shall be served within 30 days of the filing date and a proof of service filed within 60 days of the
filing date.
A Status Conference will be scheduled by the assigned Independent Calendar Judge no later than 270 days after the filing of the
complaint Counsel must be fully prepared to di'n'ts the following issues: alternative dispute resolution, bifurcation, settlement,
trial date, and expert witnesses.
The Court will require the parties at a status conference not more than 10 days before the trial to have timely filed and served all
motions in limine, bifurcation motions, statements of major evidentiary issues, dispositive motions, requested jury instructions, and
special jury instructions and special jury verdicts. These matters may be heard and resolved at this conference. Al least 5 days
before this conference, enamel must also have exchanged lists of exhibits and witnesses and have submitted to the court a brief
statement of the case to be read to the jury panel as required by Chapter Eight of the Los Angeles Superior Court Rules.
SANCTIONS
The court will impose appropriate sanctions for the failure or refusal to comply with Chapter Three Rules, orders made by the Court,
and time standards or deadlines established by the Court or by the Chapter Three Rules. Such sanctions may be on a party or if
appropriate on counsel for the party.
This is not a complete delineation of the Chapter Mite Rules, and adherenee only to the above provisions is therefore
not a guarantee against the imposition of sanctions under Trial Court Delay Reduction. Careful reading and
compliance with the actual Chapter Rules is absolutely imperative.
•
LACIV CCH 190 (Rev. 01/12)
NOTICE OF CASE ASSIGNMENT —
Page 2 of 2
LA•SC Approved 05-06
For Optional Use
EFTA01121369